Pennsylvania Insurance Law Changes

					                                     PA Insurance Department Review Requirements
                            Group IRA Flexible/Single/Fixed Premium Deferred Fixed Annuity
          (General Account/Separate Account)(With or Without Bonus, Equity Indexed, Market Value Adjustment)
                                                       Checklist
                                                                                 Updated: 06.18.02
                                                                                 APPLICABILITY
This checklist applies to group IRA deferred fixed annuity contracts and certificates with or without a bonus feature, an equity indexed feature or a market value adjustment feature.
The coverage is provided with the underlying assets of the contract and riders in the insurer's general account or separate account. This checklist is not considered all inclusive and
 only functions as a guide. For a complete understanding of filing requirements and instructions, please refer to the applicable laws and regulations. (Section 354 of the Insurance
                                                                         Company Law (40. P. S § 477b))
                REQUIREMENTS                                     REFERENCE                                                         COMMENTS

SUBMISSION PACKAGE REQUIREMENTS
                                                                                             Duplicate copies of a transmittal letter for hard copy flings. For electronic submissions,
          TRANSMITTAL LETTER                                   § 89.5 of Title 31
                                                                                             only one copy of a transmittal letter is required.
                                                                                             Duplicate copies of the annuity form(s) if submitted in hard copy. For electronic
          FORMS                                               § 89.4(a) of Title 31
                                                                                             submissions, only one copy of a form(s) is required.
                                                         Section 354 of the Insurance        An explanation of the variability of any information appearing in the forms which is
          VARIABILITY EXPLANATION
                                                        Company Law (40 P. S. § 477b)        noted as variable.

                                                                                          If a guaranteed minimum interest rate(s) is included in the contract/certificate as a
                                                                                          variable, a certification that any change in the guaranteed minimum interest rate(s) will
                                                         Section 354 of the Insurance
                                                                                          be submitted for approval prior to use. Any change in the rate(s) may be contained in
          GUARANTEED MINIMUM                               Company Law (40 P. S. §
                                                                                          an endorsement, replacement page or complete new contract/ certificate. The
          INTEREST RATE                               477b)/Section 410C of the Insurance
                                                                                          submission for approval shall be accompanied by a demonstration that the
                                                       Company Law (40 § P. S. § 510b)
                                                                                          contract/certificate continues to comply with Section 410C of The Insurance Company
                                                                                          Law (40 § P. S. § 510b).


                                                                                             If guaranteed maximum expense charge(s), surrender charge(s), or partial withdrawal
                                                                                             charge(s) are included in the contract/certificate as a variable, a certification that any
                                                          Section 354 of the Insurance
                                                                                             change in the guaranteed maximum variable charge(s) will be submitted for approval
          GUARANTEED MAXIMUM                            Company Law (40 P. S. § 477b)/
                                                                                             prior to use. Any change in the charge(s) may be contained in an endorsement,
          EXPENSE CHARGES                                Section 410C of the Insurance
                                                                                             replacement page or complete new contract /certificate. The submission for approval
                                                        Company Law (40 P. S. § 510b)
                                                                                             shall be accompanied by a demonstration that the contract/certificate continues to
                                                                                             comply with Section 410C of The Insurance Company Law (40 § P. S. § 510b) .


                                                                                      Page 1 of 26
                                      Section 354 of the Insurance
                                    Company Law (40. P.S. §477b)/
      ACTUARIAL MEMORANDUM                                              An actuarial memorandum must be provided.
                                     Section 410C of the Insurance
                                    Company Law (40 P. S. § 510b)
                                                                        A certification that the certificate applicant will be provided with a written disclosure of
                                     Section 354 of the Insurance
      BONUS CERTIFICATION                                               the bonus as required by CONTRACT/FORM PROVISIONS – BONUS section of this
                                    Company Law (40. P. S § 477b)
                                                                        checklist.
                                                                        If the underlying assets of the form are provided in the insurer's separate account, a
                                     Section 354 of the Insurance       certification that the insurer has obtained the written approval of the Commissioner of
      SEPARATE ACCOUNT AUTHORITY
                                    Company Law (40. P.S. §477b)        Pennsylvania for issuance of separate account annuity (includes variable) contracts in
                                                                        Pennsylvania.
                                                                        If the filing is being submitted on behalf of the insurer, a letter of authorization from the
                                     Section 354 of the Insurance
      AUTHORIZATION TO FILE                                             insurer preceding the filing or a letter of authorization from the insurer submitted by the
                                    Company Law (40 P. S. § 477b)
                                                                        party authorized to submit the filing.

                                     Section 354 of the Insurance       If the filing includes an insert page or uses a matrix benefit provision system, an
      INSERT PAGES
                                    Company Law (40. P. S § 477b)       explanation of when the insert page/benefit provisions will be used.

                                      Section 212 of the Insurance      Any filing fee as required by the retaliatory requirements of Section 212 of the
      FILING FEE
                                     Department Act (40 P.S. § 50)      Insurance Department Act (40 P. S. § 50)

TRANSMITTAL DOCUMENT REQUIREMENTS

                                      Section 354 of the Insurance
      REPRESENTATIVE IDENTITY                                           Identify the representative of the insurer or other party authorized to make the filing.
                                     Company Law (40 P. S. 477b)
                                     Section 354 of the Insurance
      INSURER IDENTITY                                                  Identify the insurer whose name appears on each filed form.
                                    Company Law (40 P.S. § 477b)
                                                                        Identify the general type and coverage of each form submitted: for example, group IRA
      TYPE OF INS AND COVERAGE           § 89.5(2) of Title 31
                                                                        flexible premium deferred annuity contract.

      FORM NUMBER                       § 89.5(1) of Title 31           Identify the form number of each filed form.

      GENERAL ACCOUNT/SEPARATE       Section 354 of the Insurance       State whether the underlying assets of the form are held in the general account or
      ACCOUNT IDENTIFICATION        Company Law (40 P.S. § 477b)        separate account of the insurer.




                                                                 Page 2 of 26
                              Section 354 of the Insurance
     CERTIFICATE USED WITH                                       For a certificate, identify the contract's with which the certificate will be used.
                             Company Law (40 P.S. § 477b)
                                   § 89.5(4) and (5)
                                                                 State if each form is replacing a previously approved form. If replacement is involved,
                                         and
     REPLACEMENT OF FORM                                         identify: (a) The form number of the form to be replaced. (b) The date that the form
                                 § 89.17(a) or Title 31          was approved. (c) A description of the changes made to the form to be replaced.

     INNOVATIVE FEATURES          § 89.5(3) of Title 31          Briefly describe any innovative or unique feature(s) of each form.
                                                                 State the amount of the filing fee included with the submission or the amount that will
     FILING FEE                   § 89.4(c) of Title 31
                                                                 be billed to the insurer.

ACTUARIAL MEMORANDUM

                                                                 An Actuarial memorandum must be provided which provides:
                                                                 (a) A description of the contract/certificate and contract/certificate provisions which
                                                                 affect the nonforfeiture values.
                                                                 (b) All guaranteed maximum surrender and expense charges.
                                                                 (c) A nonforfeiture demonstration that the values of the contract/certificate comply with
                                                                 the requirements of Section 410C of the Insurance Company Law (40 § P. S. 510b).
                               Section 354 of the Insurance
                                                                 The demonstration shall be provided at critical premium amounts and ages.
                             Company Law (40. P. S. §477b)/
     ACTUARIAL MEMORANDUM                                        (d) The range of issue ages.
                              Section 410C of the Insurance
                                                                 (e) The fixed maturity date, if applicable.
                             Company Law (40 P. S. § 510b)
                                                                 (f) The maximum maturity date, if the contract/certificate provides for optional maturity
                                                                 dates.
                                                                 (g) A sample calculation of the account value, surrender charge and cash surrender
                                                                 value for each schedule of surrender charges. The calculations shall properly reflect
                                                                 any withdrawal amounts made during the surrender charge period that are not subject to
                                                                 a surrender charge.




                                                          Page 3 of 26
                                                                 (h) A table of cash surrender values for at least the first 10 years, illustrating all
                                                                 contract/certificate features that affect values.
                                                                 (i) If a contract/certificate provides for a bonus: (i) A description of any adjustments in
                                                                 the credits, charges or settlement option rates necessary to offset the cost to the insurer
                                                                 for providing the bonus (e.g., the interest credit will be 1% less than the rate that would
                                Section 354 of the Insurance     be credited if the contract/certificate did not contain a bonus).
                              Company Law (40. P.S. §477b)/      (ii) If the cost of the bonus is recovered in the credits, charges or settlement option
      ACTUARIAL MEMORANDUM
                               Section 410C of the Insurance     rates but because of the pricing structure an explicit expense charge or reduction in
                              Company Law (40 P. S. § 510b)      interest credits can not be determined, a certification signed by a member of the
                                                                 American Academy of Actuaries that the actuary can not determine a specific expense
                                                                 charge or reduction in interest credits relating to the cost of the bonus.
                                                                 (j) For insurers domiciled in Pennsylvania, a description, with formulas and an
                                                                 example, of the methodology of the calculation of reserves. (k) Signature of the
                                                                 actuary who prepared and submitted the actuarial memo.


READABILITY REQUIREMENTS
                                                                  A form shall be written in simple words and with sentences as short as possible. The
                                Section 354 of the Insurance
      CLEAR EXPRESSION                                           words and sentences should convey meanings clearly and directly. Words should be
                               Company Law (40 P. S. 477b)
                                                                 used in their commonly understood senses.
                                Section 354 of the Insurance     A form shall contain a definition or explanation of terminology that would not be
      DEFINITIONS
                               Company Law (40 P. S. 477b)       ordinarily understood by a person of average intelligence.
                                Section 354 of the Insurance
      INCONSISTENT LANGUAGE                                      A form may not contain inconsistent or contradictory language or provisions.
                               Company Law (40 P. S. 477b)
                               Section 354 of the Insurance
                              Company Law (40 P. S. 477b)/
                                                                 A form that provides insurance coverage shall accurately and completely explain the
      COVERAGE EXPLANATION    Section 5(a)(1)(i) of the Unfair
                                                                 coverage and conditions of coverage.
                                 Insurance Practices Act
                                    (40 P.S. § 1171.5)

GENERAL FORM REQUIREMENTS

                                Section 354 of the Insurance
                               Company Law (40 P. S. 477b)
                                                                 The full corporate name of the insurer shall appear prominently on the first page of a
      COVER PAGE
                                                                 contract/certificate.
                                  § 89.11(a) of Title 31




                                                         Page 4 of 26
                      Section 354 of the Insurance
                                                       A marketing name or logo may be also used on the first page of a contract/certificate
                      Company Law (40 P. S. 477b)
COVER PAGE                                             provided that the marketing name or logo does not mislead as to the identity of the
                                                       insurer providing the coverage.
                          § 89.11(a) of Title 31

                      Section 354 of the Insurance
                      Company Law (40 P. S. 477b)
                                                       A current insurer address consisting of at least a city and state or province shall appear
COVER PAGE
                                                       on the first page of a contract/certificate.
                          § 89.11(a) of Title 31


                       Section 317 of the Insurance
COVER PAGE                                             Two signatures of an insurer officers shall appear on the first page of a contract.
                      Company Law (40 P. S. § 440)

                       Section 354 of the Insurance
COVER PAGE                                             At least one signature of an insurer officer shall appear on a certificate.
                      Company Law (40 P. S § 477b)

                                                       A contract/certificate shall contain, or have attached, a right to examine provision that
                                                       shall appear on the cover page of the contract/certificate or is visible without opening
                       Section 354 of the Insurance
COVER PAGE                                             the contract/certificate. For right to examine provision requirements see
                      Company Law (40 P. S § 477b)
                                                       CONTRACT/CERTIFICATE PROVISIONS-RIGHT TO EXAMINE section of this
                                                       checklist.
                                                       A form identification number shall appear at the bottom of the form in the lower left
                                                       hand corner of the form. The form number shall be adequate to distinguish the form
                                                       from all others used by the insurer. The form number may be the same as that of a form
COVER PAGE                § 89.11(b) of Title 31
                                                       to be replaced. However if the form to be replaced was approved by the Department, it
                                                       may not have been issued in this Commonwealth and shall be withdrawn from any
                                                       issuance in this Commonwealth.
                                                       A contract/certificate shall contain a brief description that shall appear prominently on
                                                       the cover page of a contract/certificate or shall be visible without opening the
                                                       contract./certificate The brief description shall contain at least the following
                                                       information:
COVER PAGE                § 89.11(d) of Title 31       (a) An indication that the form is a contract/certificate.
                                                       (b) A caption of the type of annuity coverage provided; for example, group IRA
                                                       flexible premium deferred annuity contract.
                                                       (c) An indication as to whether the contract/certificate is participating or
                                                       nonparticipating.


INSERT PAGE/BENEFIT     Section 354 of the Insurance   Insert pages/benefit provisions may be filed with a statement explaining when the insert
PROVISIONS             Company Law (40 P. S. 477b)     pages/benefit provisions will be used.

                                               Page 5 of 26
                                                                     The specifications page of a form shall be completed with hypothetical data which is
      SPECIFICATIONS PAGE              § 89.11(c) of Title 31        realistic and consistent with the other contents of the form and any required actuarial
                                                                     memorandum.

                                   Section 354 of the Insurance      The certificate specification page shall include the date annuity payments are scheduled
      SPECIFICATIONS PAGE
                                  Company Law (40 P. S. § 477b)      to begin under the certificate, i.e. the maturity date or annuity date.

                                                                     Any information appearing in a contract/certificate which is variable shall be bracketed
                                                                     or otherwise marked to denote variability. Variability is limited to “John Doed”
                                    Section 354 of the Insurance     information specifically relating to a particular insured (e.g. name), to guaranteed
      VARIABILITY
                                   Company Law (40 P.S. § 477b)      interest rate, expense charges, surrender charges and partial withdrawal charges, and to
                                                                     any initial guaranteed interest rates, expense charges, surrender charges and partial
                                                                     withdrawal charges and to any severable riders.

                                                                     "DEPOSIT" - No form may describe or refer to premium payments as "deposits."
      TERMINOLOGY                      § 87.28(2) of Title 31
                                                                     Premium payments may be describe or referred to as "premium deposits."
                                                                     “LEGAL RESERVE” – No reference may appear in a form to “legal reserve", “old line
      TERMINOLOGY                        § 139 of Title 31           life reserve", or a similar phrase as descriptive of an insurer transacting business in the
                                                                     Commonwealth.

                                                                     “SPECIAL” – The word “special may not be used in any way that might reasonably
      TERMINOLOGY                      § 89.13(c) of Title 31
                                                                     cause the owner or insured to believe that he/she is receiving preferential treatment.

CONTRACT/CERTIFICATE PROVISIONS

      ABSENCE OF CASH SURRENDER   Section 410C(i) of the Insurance   If a contract/certificate does not provide cash surrender benefits, a statement to that
      BENEFITS                    Company Law (40 P. S. § 510b(i)    effect shall be included in the contract/certificate in a prominent place.

                                                                     A contract/certificate may not provide for unilateral amendments which reduce or
      AMENDMENTS                   Section 89.16(c) of Title 31
                                                                     eliminate benefits or coverage under the contract/certificate.
                                                                     A contract/certificate may provide for arbitration. If a contract/certificate contains an
                                                                     arbitration provision, the provision shall provide:
                                                                     (a) Whether arbitration is binding or non-binding.
                                                                     (b) If arbitration is binding, whether it is non-voluntary (mandatory) or voluntary.
                                   Section 354 of the Insurance      (c) If the arbitration provision provides for an appeal procedure by the contract
      ARBITRATION
                                  Company Law (40 P. S. § 477b)      owner/certificate holder to the insurer that must be exhausted before the contract
                                                                     owner/ certificate holder may resort to any litigation and if the provision specifies a
                                                                     period of time within which a written appeal must be filed (e.g., 60 days), that failure to
                                                                     file within the specified period will not invalidate an appeal if it is shown that the appeal
                                                                     was filed as soon as reasonably possible.


                                                             Page 6 of 26
                                                                1. A contract/certificate providing a bonus shall clearly describe any amount credited to
                            Section 354 of the Insurance
BONUS                                                           the account value, cash surrender value and/or annuity value in addition to the credited
                           Company Law (40 P. S. § 477b)
                                                                interest rate(s), including any conditions or limitations that apply to the bonus.

                                                                2. For a contract/certificate providing a bonus, the applicant shall be provided with a
                                                                written disclosure of the bonus no later than the time the application form is signed by
                                                                the applicant. The disclosure shall include the following:
                                                                (a) A clear description of the bonus and any conditions or limitations that apply to the
                                                                bonus.
                                                                (b) If applicable, a clear description of any adjustments in the credits, charges or
                                                                settlement option rates necessary to offset the cost to the insurer for providing the bonus
                            Section 354 of the Insurance
BONUS                                                           (e.g. the interest credits will be 1% less than the rate would be credited if the form did
                           Company Law (40 P. S. § 477b)
                                                                not contain a bonus). If because of the pricing structure, an explicit expense charge or
                                                                reduction in interest credits can not be determined, a general description that the
                                                                expense charges may be higher or interest credit lower than the charges or credits for a
                                                                contract/certificate without the bonus and that the amount of the charges or reduction in
                                                                interest credits may exceed the amount of the bonus or an alternative description that
                                                                provides the same level or degree of disclosure and is found acceptable by the
                                                                Department.
                                                                Any claims of creditors language included in a form shall be in compliance with 42 Pa.
CLAIMS OF CREDITORS            42 Pa. C.S.A. § 8124(c)
                                                                C.S.A. § 8124(c).
                                                                If in any year the death benefit is less than the minimum nonforfeiture amount as
DEATH BENEFIT LESS THAN
                            Section 410C of the Insurance       required by Section 410C of The Insurance Company Law (40 P. S. § 510b), a
MINIMUM NONFORFEITURE
                           Company Law (40 P. S. 510b(i))       statement shall be included in the contract/certificate in a prominent place that such
AMOUNT
                                                                benefits are not provided.

                                                            1. A contract/certificate shall contain a provision regarding what constitutes the entire
                                                            contract between the insurer and the contract/certificate owner. The provision shall
                                                            provide that the contract/certificate shall constitute the entire contract. However, if the
                                                            application is to be a part of the contract/certificate, the entire contract provision shall
                           Section 410B(c) of the Insurance
ENTIRE CONTRACT                                             state that the contract/certificate and the application constitute the entire
                          Company Law (40 P. S. § 510a(c))
                                                            contract/certificate.
                                                            2. If the insurer desires to make the application a part of the contract/certificate a copy
                                                            of the application shall be indorsed upon or attached to the contract/certificate when
                                                            issued.

                                                                If the contract/certificate provides for the use of an index outside the control of the
                            Section 354 of the Insurance
EXTERNAL INDEX                                                  insurer, the contract/certificate shall provide that if the index is no longer available a
                           Company Law (40 P. S. § 477b)
                                                                substitute index shall be submitted to the Department for approval.


                                                      Page 7 of 26
                                                         1. Any interest rates, expense charges, surrender charges and partial withdrawal
                                                         charges, used in the determination of the account value, cash surrender value and death
                                                         benefit, and stated in a contract/certificate shall be guaranteed. Nonguaranteed interest
                                                         rates, expense charges, surrender charges, and partial withdrawal charges may not be
                     Section 354 of the Insurance        included in a contract/certificate.
FORM GUARANTEES
                    Company Law (40 P. S. § 477b)        2. All tables of values contained in a contract/certificate shall be based on the
                                                         guaranteed minimum interest rate(s), and guaranteed maximum expense charges,
                                                         surrender charges and partial withdrawal charges, stated in a contract/certificate,
                                                         including any initial guaranteed interest rates, expense charges, surrender charges and
                                                         partial withdrawal charges stated in a contract/certificate.

                                                    If a contract/certificate provides for payments of a fixed premium, the
                                                    contract/certificate shall contain a grace period provision for the payment of the
                                                    premium. The provision shall provide: (a) A grace period of at least 30 days or one
                                                    month. (b) At the option of the insurer, interest may be charged at a rate specified in
                     Section 410B of the Insurance  the contract/certificate on an overdue payment. If interest is charged, the rate may not
GRACE PERIOD
                   Company Law (40 P. S. § 510a(a)) exceed 8% per annum for the number of days of grace elapsing before payment. (c)
                                                    During the grace period, the certificate shall continue in full force. (d) If the certificate
                                                    becomes a claim on account of death during the grace period before any overdue
                                                    payment is paid, the amount of such payments, with interest, may be deducted at
                                                    settlement.


                                                     1. A contract/certificate shall contain an incontestability provision. The provision shall
                                                     provide:
                                                     (a) A contestable period of no greater than 2 years during the lifetime of the insured.
                                                     (b) Only the following exceptions to the incontestability provision: (i) Conditions of
                    Section 410B(b) of the Insurance
                                                     the contract/certificate relating to military or naval service in time of war. (ii) At the
                   Company Law (40 P. S. § 510a(b))/
INCONTESTABILITY                                     option of the insurer, provisions related to benefits in the event of total and permanent
                    Section 410B(c) of the Insurance
                                                     disability. (iii) At the option of the insurer, provisions which grant insurance
                   Company Law (40 P. S. § 510a(c))
                                                     specifically against death by accident.
                                                     2. Coverage may be contested only based on a statement contained in an application. If
                                                     the insurer expects to rely on an application to contest the contract/certificate, the
                                                     insurer shall attach or otherwise make the application a part of the contract/certificate.


                                                         1. A contract/certificate which develops cash values may provide for a loan provision.
                      Section 354 of the Insurance
                                                         2. The interest rate shall be at a maximum of 8% per annum or an adjustable rate
                    Company Law (40 P. S. § 477b)/
LOANS                                                    determined in accordance with Section 410F of The Insurance Company Law (40 P. S.
                     Section 410F of the Insurance
                                                         510e).
                     Company Law (40 P. S. 510e)
                                                         3. Interest may be collected in advance to the end of the current year.


                                                Page 8 of 26
                                                                    If a contract/certificate provides the certificate owner with the right to change the
                                 Section 354 of the Insurance
MATURITY DATE                                                       maturity date, the provision shall contain sufficient latitude to allow the
                                Company Law (40 P. S. § 477b)
                                                                    contract/certificate to be tax qualified.

                                 Section 354 of the Insurance
MINIMUM PREMIUM                                                     A contract/certificate shall state any minimum contract premium requirements.
                                Company Law (40 P. S. § 477b)

                                                                A contract/certificate shall contain a misstatement of age provision. The provision shall
                                                                provide:
                                                                (a) If there is a misstatement of age, the amount payable shall be such as the payment(s)
                               Section 410B(d) of the Insurance
MISSTATEMENT OF AGE                                             to the insurer would have purchased at the correct age(s).
                              Company Law (40 P. S. § 510a(d))
                                                                (b) Any overpayment(s) by the insurer on account of misstatement of age shall, with
                                                                interest at a rate specified in the contract/certificate but not exceeding 6%, be charged
                                                                against the current or next succeeding payment(s) to be made by the insurer.
                                                                    If a contract/certificate is written on a sex distinct basis, a contract shall contain a
                                                                    misstatement of sex provision. The provision shall provide:
                                                                    (a) If there is a misstatement of sex, the amount payable shall be such as the payment(s)
                               Section 410B(d) of the Insurance     to the insurer would have purchased at the correct sex.
MISSTATEMENT OF SEX
                               Company Law (40 P.S. §510a(d))       (b) Any overpayment(s) by the insurer on account of misstatement of sex shall, with
                                                                    interest at a rate specified in the contract/certificate but not exceeding 6%, be charged
                                                                    against the current or next succeeding payment(s) to be made by the insurer.

                                                                    1. A contract/certificate shall contain the following provisions or corresponding
                                                                    provisions which in the opinion of the Insurance Commissioner are at least as favorable
                                                                    to the owner as the following:
                                                                    (a) A provision that upon cessation of payment of considerations under the certificate,
                                                                    the insurer will grant a paid-up annuity benefit on a plan as stipulated in the
                              Section 410C(c)(1) of the Insurance
                                                                    contract/certificate.
NONFORFEITURE VALUES – FORM   Company Law (40 P.S. §510b(c)(1))/
                                                                    (b) If the contract/certificate provides for a lump sum settlement at maturity or at any
PROVISIONS                    Section 410C(c)(2) of the Insurance
                                                                    other time, a provision that upon surrender of the certificate at or prior to the
                              Company Law (40 P.S. §510b(c)(2))
                                                                    commencement of any annuity payments, the insurer will pay in lieu of any paid-up
                                                                    annuity benefit a cash surrender benefit.
                                                                    (c) A provision that the insurer reserves the right to defer the payment of any cash
                                                                    surrender or partial withdrawal for a period of six months after demand of the cash
                                                                    surrender benefit with surrender of the certificate.




                                                          Page 9 of 26
                                                                    (d) A statement of the mortality table, if any, and interest rates used in calculating any
                                                                    minimum paid-up annuity, cash surrender or death benefits that are guaranteed under
                                                                    the contract/certificate, together with sufficient information to determine the amounts of
                                                                    such benefits. The sufficient information includes all expense, partial withdrawal and
                                                                    surrender charges.
                              Section 410C(c)(3) of the Insurance
                                                                    (e) A statement that any paid-up annuity, cash surrender or death benefits that may be
NONFORFEITURE VALUES – FORM   Company Law (40 P.S. §510b(c)(3))/
                                                                    available under the contract/certificate are not less than the minimum benefits required
PROVISIONS                    Section 410C(c)(4) of the Insurance
                                                                    by Pennsylvania statute or the statute of the state in which the contract/certificate is
                              Company Law (40 P.S. §510b(c)(4))
                                                                    delivered.
                                                                    (f) An explanation of the manner in which the paid-up annuity, cash surrender or death
                                                                    benefits are altered by the existence of any additional amounts credited by the insurer to
                                                                    the certificate, any indebtedness to the insurer on the certificate or any prior
                                                                    withdrawals from or partial surrenders of the certificate.

                                                                  2. A contract/certificate may provide that if no considerations have been received under
                                                                  a certificate for a period of two full years and the portion of the paid-up annuity benefit
                                                                  at maturity on the plan stipulated in the contract/certificate arising from considerations
                              Section 410C(c)(4) of the Insurance
                                                                  paid prior to such period would be less than $20 monthly, the insurer may at its option
                                   Company Law (40 P. S. §
NONFORFEITURE VALUES – FORM                                       terminate such form by payment in cash of the present value of such portion of the paid-
                                         510b(c)(4))/
PROVISIONS                                                        up annuity benefit, calculated on the basis of the mortality table, if any, and interest rate
                                 Section 354 of the Insurance
                                                                  specified in the contract/certificate for determining the paid-up annuity benefit, and by
                               Company Law (40 P. S. § 477b)
                                                                  such payment shall be relieved of any further obligation under such certificate.
                                                                  3. A contract/certificate may not provide that a premium shall be credited to the
                                                                  certificate on a day beyond the first business day after receipt of the premium.

                                                                    Cash surrender values and nonforfeiture benefits of the contract/certificate shall comply
NONFORFEITURE VALUES –           Section 410C of the Insurance
                                                                    with the nonforfeiture requirements of the Standard Nonforfeiture Law for Individual
COMPUTATION OF VALUES           Company Law (40 P. S. § 510b)
                                                                    Deferred Annuities (40 P. S. § 510b).

                                                                    1. If a certificate develops cash values, the contract/certificate may provide for a partial
                                                                    withdrawal provision. The contract/certificate shall contain the conditions applicable to
                                                                    a partial withdrawal. 2. If the underlying assets of the contract/certificate are in the
                                                                    general account of the insurer, any partial withdrawal provision shall be constructed so
                                                                    that general account modified guaranteed annuity contract owners/certificate holders
                                  Section 354 of the Insurance      who have not exercised such provision are not disadvantaged by the exercise thereof by
PARTIAL WITHDRAWAL
                                 Company Law (40 P.S. §477b)        other general account modified guaranteed annuity owners. 3. If the underlying assets
                                                                    of the contract/certificate are in the separate account of the insurer, any partial
                                                                    withdrawal provision shall be constructed so that separate account modified guaranteed
                                                                    annuity contract owners/certificate holders who have not exercised such provision are
                                                                    not disadvantaged by the exercise thereof by other separate account modified
                                                                    guaranteed annuity owners.

                                                          Page 10 of 26
                                                                   1. If a contract/certificate participates in the divisible surplus of the insurer, the
                                                                   contract/certificate shall contain a participation in surplus provision. The provision shall
PARTICIPATION IN DIVISIBLE     Section 410B(e) of the Insurance
                                                                   provide:
SURPLUS                        Company Law (40 P.S. § 510a(e))
                                                                   (a) The insurer must annually ascertain and apportion any divisible surplus.
                                                                   (b) The contract owner/certificate holder may receive any dividend paid in cash.

                                 Section 354 of the Insurance      A contract/certificate may not provide that a premium shall be credited to the certificate
PREMIUM CREDITING
                                Company Law (40 P.S. §477b)        on a day beyond the first business day after receipt of the premium.

                                                                 1. A contract/certificate that requires payment of fixed premiums shall contain a
                                                                 reinstatement provision. The provision shall provide: (a) The contract/certificate may
                                                                 be reinstated unless the contract/certificate has been surrendered. (b) A period of
                                Section 410B(g) of the Insurance reinstatement not less than 1 year from the date of default in making the stipulated
                                   Company Law (40 P. S. §       payment. (c) Any evidence of insurability requirements. (d) At the option of the
REINSTATEMENT                     510a(g))/Section 410F of the   insurer, payment of overdue stipulated payments may be required. Interest may be
                              Insurance Company Law (40 P. S. § charged. The rate must be disclosed at a specified rate. The specified rate may not
                                             510e)               exceed 8% per annum. (e) At the option of the insurer if applicable,
                                                                 repayment/reinstatement of any indebtedness may be required with an interest rate(s)
                                                                 not exceeding 8% per annum or an adjustable rate determined in accordance with
                                                                 Section 410F of the Insurance Company Law (40 P. S. § 510e).
                                Section 410B(g) of the Insurance   2. With respect to statements made in an application for reinstatement, the certificate is
                                   Company Law (40 P. S. §         incontestable after it has been in force during the insured's lifetime for 2 years
REINSTATEMENT                     510a(g))/Section 410F of the     beginning with the day of reinstatement. The contestable period is based only on
                              Insurance Company Law (40 P. S. §    statements in the reinstatement application, unless the original contestable period has
                                             510e)                 not yet expired.

                                                                   1. A contract/certificate shall provide for the delivery, at least annually and without
                                                                   charge, of a report to the owner which serves to keep the certificate owner advised as to
                                                                   the status of the certificate.
                                                                   2. The end of the current report period may not be more than 3 months prior to the date
                                                                   of the mailing of the report.
                                                                   3. The report shall contain at least the following information:
                                                                   (a) The beginning and ending date of the current report period.
                                 Section 354 of the Insurance
REPORT TO CERTIFICATE OWNER                                        (b) The account value, if any, at the beginning of the current report period and at the
                                Company Law (40 P. S. § 477b)
                                                                   end of the current report period.
                                                                   (c) The cash surrender value, if any, at the end of the current report period.
                                                                   (d) The amounts, if any, that have been credited or debited to the certificate during the
                                                                   current report period. The credited and debited amounts shall be identified by type; for
                                                                   example, premium payments, interest credits, bonus credits, persistency credits, expense
                                                                   charges, withdrawal amounts and withdrawal charges.
                                                                   (e) The amount of outstanding loans, if any, as of the end of the current report period.


                                                         Page 11 of 26
                                                     1. A Right to Examine provision shall appear on the cover page of a
                                                     contract/certificate, be visible without opening the contract/certificate or be attached to
                                                     the cover page. The provision shall provide:
                                                     (a) A minimum of 10 days to examine the contract/certificate and return the
                                                     contract/certificate if the owner is not satisfied with the contract/certificate for any
                                                     reason. The days shall begin on the date the contract/certificate is delivered to the
                      Section 354 of the Insurance
RIGHT TO EXAMINE                                     owner. If no replacement of existing insurance is involved, the minimum number of
                     Company Law (40 P. S. § 477b)
                                                     days is 10. If replacement involving non-affiliated insurers is involved, the minimum
                                                     number of days is 20. If replacement involving affiliated insurers is involved, the
                                                     minimum number of days is 45.
                                                     (b) A requirement for the return of the contract/certificate.
                                                     (c) A refund of any premium paid if the contract/certificate is returned.
                                                     (d) For payment of the refund amount to the owner.
                                                     1. A contract/certificate shall specify a default settlement option at maturity. The
                                                     default option shall be a life annuity with a period certain of at least 5 years unless
                                                     otherwise provided under the Internal Revenue Code.
                      Section 354 of the Insurance   2. A contract/certificate shall contain a provision that settlement of the death benefit
SETTLEMENT
                     Company Law (40 P.S. §477b)     proceeds shall be made to the beneficiary upon receipt of due proof of death promptly.
                                                     If a contract/certificate provides a settlement option or options in addition to lump-sum
                                                     payment, the contract/certificate shall specify a default method of paying the death
                                                     benefit proceeds.

                                                     1. A contract/certificate shall guarantee for the life of the contract certificate the
                                                     availability of each form of settlement option specified in the contract.
                                                     2. A contract/certificate shall contain a description of guaranteed minimum pay out
                      Section 354 of the Insurance   amounts for each form of settlement option specified in the contract/certificate. The
SETTLEMENT OPTIONS
                     Company Law (40 P.S. §477b)     guaranteed interest rate and mortality table, if applicable, being utilized for a payout
                                                     shall be identified in the contract/certificate. In lieu of the interest rate and mortality
                                                     table disclosure, complete tables of settlement option payout amounts shall be included
                                                     in the contract/certificate.

                                                     3. The interest rate and mortality table, if applicable, or the tables of payout amounts
                                                     shall be guaranteed for at least the first 5 certificate years or for at least the first
                                                     certificate year with the stipulation that payout amounts will not be increased more
                                                     often than once a certificate year thereafter. If the interest rate and mortality table, if
                      Section 354 of the Insurance   applicable, or the tables of payout amounts are guaranteed for less than the entire life of
SETTLEMENT OPTIONS
                     Company Law (40 P. S. §477b)    the contract/certificate, then the contract/certificate shall provide for at least 90-days
                                                     notice prior to any change in the interest rate and mortality table, if applicable, or in the
                                                     tables of payout amounts. In addition, the contract/certificate shall disclose that the
                                                     guaranteed minimum payout amounts are subject to change. This disclosure shall be
                                                     visible without opening the contract/certificate.

                                             Page 12 of 26
                                                                                   A contract/certificate shall define the following terms or terms of similar import:
                                                    Section 354 of the Insurance
                                                                                   (a) Death benefit.
                                                  Company Law (40 P. S. § 477b)/
         VALUES DEFINED                                                            (b) Account value.
                                                   Section 410C of the Insurance
                                                                                   (c) Cash surrender value.
                                                  Company Law (40 P. S. § 510b)
                                                                                   (d) Annuity value.

SPECIALIZED PRODUCTS – ADDITIONAL REQUIREMENTS


EQUITY INDEXED ANNUITIES (An annuity form with interest credits or benefits that are linked to an external equity referent or an equity index).

                                                                                   The submission package shall include in addition to the SUBMISSION PACKAGE
                                                                                   REQUIREMENTS of this checklist the following:
                                                                                   (a) An actuarial memorandum which provides a sample calculation of the indexed
                                                    Section 354 of the Insurance
                                                                                   account values and indexed surrender values, including the affect of any surrender
                                                  Company Law (40 P.S. § 477b)/
                                                                                   charge and any maximum/minimum limit on the index adjustment.
         SUBMISSION PACKAGE                        Section 410C of the Insurance
                                                                                   (b) A copy of the disclosure form required by EQUITY INDEXED ANNUITIES -
                                                  Company Law (40 P.S. § 510b)
                                                                                   DISCLOSURE section of this checklist for review and Department acceptance.
                                                                                   (c) A certification that the certificate applicant will be provided with a summary
                                                                                   explanation of the principal features of the equity indexed annuity as required by
                                                                                   EQUITY INDEXED ANNUITIES - DISCLOSURE section of this checklist.


                                                   Section 354 of the Insurance    The following general form requirements are in addition to the GENERAL FORM
                                                  Company Law (40 P.S. § 477b)     REQUIREMENTS - COVER PAGE requirements of this checklist: (a) The brief
                                                                                   description of an equity indexed annuity contract/certificate shall disclose that the form
         GENERAL FORM REQUIREMENTS -                                               is an “equity indexed annuity”. Alternatively, the contract/certificate cover page may
         COVER PAGE                                                                elsewhere contain a disclosure in prominent print that the contract/certificate is an
                                                                                   "equity indexed annuity."
                                                      § 89.11(d) of Title 31       (b) If the death benefit is not subject to an index adjustment, the disclosure required by
                                                                                   (a) shall disclose the non-applicability.


                                                                                   The following general form requirement is in addition to the GENERAL FORM
                                                                                   REQUIREMENTS - VARIABILITY requirements of this checklist: Any information
                                                                                   appearing in the contract/certificate which is variable shall be bracketed or otherwise
         GENERAL FORM REQUIREMENTS -               Section 354 of the Insurance    marked to denote variability. In addition to the variable items referenced in GENERAL
         VARIABILITY                              Company Law (40 P.S. § 477b)     FORM REQUIREMENTS - VARIABILITY, variability is limited to guaranteed
                                                                                   participation rate(s), floor(s), cap(s) and margin(s) applicable to index increases and to
                                                                                   any initial guaranteed participation rate(s), floor(s), cap(s) and margin(s) applicable to
                                                                                   index increases.



                                                                          Page 13 of 26
                                                       The following contract/form provisions are in addition to the CONTRACT/
                                                       CERTIFICATE PROVISIONS requirements of this checklist. (a) The form shall
                                                       describe how the equity index values or benefits are determined.
                                                       (b) The contract/certificate shall disclose the specific equity index used (e.g. Standard
CONTRACT/CERTIFICATE    Section 354 of the Insurance   and Poor’s 500 Index)
PROVISIONS             Company Law (40 P. S. § 477b)   (c) The contract/certificate shall disclose any participation rate(s), floor(s), cap(s) and
                                                       margin(s) applicable to equity index increases. Nonguaranteed participation rate(s),
                                                       floor(s), cap(s) and margin(s) applicable to equity index increases may not be included
                                                       in a contract/certificate.


                                                       The following disclosure requirements are in addition to the CONTRACT/
                                                       CERTIFICATE PROVISIONS requirements of this checklist. 1. No later than the time
                                                       the enrollment form is signed, the applicant shall be provided with a disclosure of the
                                                       certificate features.
                                                       2. The disclosure shall include a description of the certificate and its specific features,
                                                       including examples where appropriate. The examples may be based on assumed
                                                       premiums. The description shall include:
                        Section 354 of the Insurance   (a) How the minimum guaranteed values and index adjusted values are calculated.
DISCLOSURE
                       Company Law (40 P. S. § 477b)   (b) An explanation of the participation rate, spread rate and maximum/minimum
                                                       amount of index adjustment.
                                                       (c) The duration of the initial participation rate, initial spread rate and initial
                                                       minimum/maximum amount of index adjustment
                                                       (d) A statement that the participation rate, spread rate and minimum/maximum amount
                                                       of index adjustment may change from time to time subject to the guarantees of the
                                                       contract/certificate.
                                                       (e) If applicable, the fact that the death benefit is not subject to any index adjustment.

                                                       3. The disclosure shall include the language of the right to examine contract provision
                                                       required by Section 410E of the Insurance Company Law (40 P. S. § 510d).
                                                       4. The disclosure may not be deemed to have been satisfied to the extent that it is
                        Section 354 of the Insurance   provided in the form of one of the following:
DISCLOSURE
                       Company Law (40 P. S. § 477b)   (a) A prospectus delivered subject to the prospectus delivery requirements of the
                                                       Securities Act of 1933.
                                                       (b) The information and reports required by the Employee Retirement Income Security
                                                       Act of 1974.




                                              Page 14 of 26
                                                                                  1. The following report to owner requirements are in lieu of the REPORT TO OWNER
                                                                                  requirements of this checklist. (a) A contract/certificate shall provide for the delivery, at
                                                                                  least annually and without charge, of a report to the certificate owner which serves to
                                                                                  keep the certificate owner advised as to the status of the form.
                                                                                  (b) The end of the current report period may not be more than 3 months prior to the
                                                                                  date of the mailing of the report.
                                                                                  (c) The report shall contain at least the following information:
                                                Section 354 of the Insurance
        REPORT TO CERTIFICATE OWNER                                               (i) The beginning and ending date of the current report period.
                                               Company Law (40 P. S. § 477b)
                                                                                  (ii) The minimum guaranteed cash value at the beginning of the current report period
                                                                                  and at the end of the current report period.
                                                                                  (iii) The amounts, if any, that have been credited or debited to the minimum guaranteed
                                                                                  cash surrender value during the current report period. The credited and debited
                                                                                  amounts shall be identified by type; for example, premium payments, interest credits,
                                                                                  bonus credits, persistency credits, expense charges, withdrawal amounts and withdrawal
                                                                                  charges.


                                                                                  (d) The vested index adjusted account value at the beginning of the current report
                                                                                  period and at the end of the current report period.
                                                                                  (e) The amount, if any, that have been credited or debited to the vested index adjusted
                                                Section 354 of the Insurance      account value during the current report period. The credited and debited amounts shall
        REPORT TO CERTIFICATE OWNER
                                               Company Law (40 P. S. § 477b)      be identified by type; for example, premium payments, interest credits, bonus credits,
                                                                                  persistency credits, expense charges, withdrawal amounts and withdrawal charges.
                                                                                  (f) The cash surrender value, if any, at the end of the current report period.
                                                                                  (g) The amount of outstanding loans, if any, as of the end of the current report period.


GENERAL ACCOUNT MODIFIED GUARANTEED A DEFERRED ANNUITY (A deferred annuity under which the values are subject to a market value adjustment unless held
for guarantee periods specified in the contract/certificate. )
                                                                                 The submission package shall include in addition to the SUBMISSION PACKAGE
                                                                                 REQUIREMENTS of this checklist, the following: (a) State that the contract/certificate
                                                                                 contains a market value adjustment provision. (b) If a guaranteed minimum interest
                                                                                 rate(s) is included in the contract/certificate as a variable, a certification that any
                                                Section 354 of the Insurance     change in the guaranteed minimum interest rate(s) used in the calculation of the
                                                  Company Law (40 P. S. §        adjusted cash value will be submitted for approval prior to use. Any change in the
        SUBMISSION PACKAGE
                                             477b)/Section 410C of the Insurance rate(s) may be contained in an endorsement, replacement page or complete new
                                              Company Law (40 P. S. § 510b) contract/certificate. The submission for approval shall be accompanied by a
                                                                                 demonstration that the contract/certificate continues to comply with the GENERAL
                                                                                 ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY -
                                                                                 NONFORFEITURE VALUES-COMPUTATION OF VALUES section of this
                                                                                 checklist.

                                                                        Page 15 of 26
                                                           (c) If guaranteed maximum expense charge(s), surrender charge(s), or partial
                                                           withdrawal charge(s) are included in the contract/certificate as a variable, a certification
                                                           that any change in the guaranteed maximum variable charge(s) used in the calculation of
                          Section 354 of the Insurance     the adjusted cash value will be submitted for approval prior to use. Any change in the
                            Company Law (40 P. S. §        charge(s) may be contained in an endorsement, replacement page or complete new
SUBMISSION PACKAGE
                       477b)/Section 410C of the Insurance contact/certificate. The submission for approval shall be accompanied by a
                        Company Law (40 P. S. § 510b) demonstration that the contract/certificate continues to comply with the GENERAL
                                                           ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY -
                                                           NONFORFEITURE VALUES-COMPUTATION OF VALUES section of this
                                                           checklist.

                                                           (d) If the market value adjustment formula or any rates or factors used in the market
                                                           value adjustment formula are included in the contract/certificates a variable, a
                                                           certification that any change in the formula or any rate or factor used in the formula will
                                                           be submitted to the Department for approval prior to use. If the market value
                          Section 354 of the Insurance     adjustment formula is revised, the request for approval shall include an actuarial
                            Company Law (40 P. S. §        memorandum submitted in accordance with the GENERAL ACCOUNT MODIFIED
SUBMISSION PACKAGE
                       477b)/Section 410C of the Insurance GUARANTEED DEFERRED ANNUITY - ACTUARIAL MEMORANDUM
                        Company Law (40 P. S. § 510b) requirements of this checklist. If any rates or factors used in the formula are revised, the
                                                           request for approval shall include an actuarial memorandum indicating the
                                                           reasonableness of the revised rate or factor. Any change in the formula or any rates or
                                                           factors used in the formula may be contained in an endorsement, replacement page or
                                                           complete new contract/certificate.


                                                           The following actuarial memorandum requirements are in lieu of the ACTUARIAL
                                                           MEMORANDUM requirements of this checklist. An actuarial memorandum which
                                                           provides: (a) A description of the contract/certificate and provisions which affect
                        PENNSYLVANIA INSURANCE nonforfeiture values. (b) An identification of market value adjustment guarantee periods
                         DEPARTMENT NO. 1994-11/           of time available at issue of the contract/certificate. (c) All guaranteed maximum
                          Section 354 of the Insurance     surrender and expense charges. (d) A statement that the market value adjustment
ACTUARIAL MEMORANDUM
                            Company Law (40 P. S. §        formula provides reasonable equity to both the certificate owner and the insurer and the
                       477b)/Section 410C of the Insurance basis for this statement. (e) A sample calculation of the account value, surrender
                        Company Law (40 P. S. § 510b) charge, both an upward and downward market value adjustment and adjusted cash
                                                           surrender value for each schedule of surrender charges. The calculations shall properly
                                                           reflect any withdrawal amounts made during the surrender charge period that are not
                                                           subject to a surrender charge.




                                                   Page 16 of 26
                                                           (f) If the market value adjustment provision refers to an index outside the control of the
                                                           insurer, an explanation of the reasonableness of the index. Any request for Department
                        PENNSYLVANIA INSURANCE acceptance of the substitution of an index outside the control of the insurer shall include
                         DEPARTMENT NO. 1994-11/           an actuarial memorandum indicating the reasonableness of the substitute index. (g) If
                          Section 354 of the Insurance     the market value adjustment formula contains a factor that represents a charge to cover
ACTUARIAL MEMORANDUM
                            Company Law (40 P. S. §        items such as transaction costs, timing risk and/or credit risk, an explanation how this
                       477b)/Section 410C of the Insurance charge relates to each of these items. (h) A nonforfeiture demonstration that the adjusted
                        Company Law (40 P. S. § 510(b) cash surrender values comply with the requirements of Section 410C of the Insurance
                                                           Company Law (40 P. S. § 510b) The demonstration shall be provided at critical
                                                           premium amounts and ages.
                                                           (i) If the contract/certificate provides for partial withdrawals, two numeric examples
                                                           illustrating the application of the market value adjustment to partial withdrawals,
                        PENNSYLVANIA INSURANCE
                                                           including how any minimum on the amount of the market value adjustment will be
                         DEPARTMENT NO. 1994-11/
                                                           administered on partial withdrawals. One example shall illustrate a partial withdrawal
                          Section 354 of the Insurance
ACTUARIAL MEMORANDUM                                       occurring with a significant downward market value adjustment, followed shortly
                            Company Law (40 P. S. §
                                                           thereafter by a full surrender with an upward market value adjustment. The other
                       477b)/Section 410C of the Insurance
                                                           example shall illustrate a partial withdrawal occurring with a significant downward
                        Company Law (40 P. S. § 510(b)
                                                           market value adjustment, followed shortly thereafter by a full surrender with a
                                                           significant downward market value adjustment.

                                                           (j) A table of cash surrender values for the first 10 years of a certificate illustrating an
                                                           initial guarantee period and at least one renewal guarantee period. The table shall be
                                                           based on the guaranteed minimum interest rate or rates and maximum expense and
                        PENNSYLVANIA INSURANCE
                                                           surrender charges. If the contract/certificate allows for alternative interest rate
                         DEPARTMENT NO. 1994-11/
                                                           guarantee periods after the initial interest rate guarantee period, the table shall be based
                          Section 354 of the Insurance
ACTUARIAL MEMORANDUM                                       on the default renewal period provided in the form. The table shall be based on level
                            Company Law (40 P. S. §
                                                           premiums payable once each year. (k) The range of issue ages. (l) The maximum
                       477b)/Section 410C of the Insurance
                                                           maturity date, if the contract/ certificate provides for optional maturity dates. (m) The
                        Company Law (40 P. S. § 510(b)
                                                           fixed maturity date, if applicable. (n) For insurers domiciled in Pennsylvania, a
                                                           description, with formulas and an example, of the methodology of the calculation of
                                                           reserves. (o) Signature of the actuary who prepared the actuarial memorandum.




                                                    Page 17 of 26
                                                                 The following general form requirements are is in addition to the GENERAL FORM
                              PENNSYLVANIA INSURANCE             REQUIREMENT - COVER PAGE requirements of this checklist: The cover page of a
                               DEPARTMENT NO. 1994-11/           modified guaranteed annuity contract/certificate shall contain a statement that cash
                                                                 surrender values may increase or decrease in accordance with a market value
GENERAL FORM REQUIREMENTS -                                      adjustment prior to a date or dates specified in the contract/certificate. A statement
COVER PAGE                                                       shall be made that any increase or decrease in the cash surrender values is subject to the
                                   § 89.11(d) of Title 31        minimum values defined in the contract/certificate. A statement shall also be included
                                                                 of the effect, if any, that a market value adjustment has on the death benefit. The
                                                                 statement(s) shall appear in a prominent location in prominent type on the cover page or
                                                                 caption.
                                                                 The following general form requirement is in addition to the GENERAL FORM
                                                                 REQUIREMENTS - VARIABILITY requirements of this checklist: Any information
                                                                 appearing in the contract/certificate which is variable shall be bracketed or otherwise
GENERAL FORM REQUIREMENTS -    Section 354 of the Insurance
                                                                 marked to denote variability. In addition to the variable items referenced in GENERAL
VARIABILITY                   Company Law (40 P. S. § 477b)
                                                                 FORM REQUIREMENTS- VARIABILITY, variability is limited to the market value
                                                                 adjustment formula and any rates or factors used in the market value adjustment
                                                                 formula.
                                                                 The following contract/certificate provisions are in addition to the CONTRACT/
                              PENNSYLVANIA INSURANCE             CERTIFICATE requirements of this checklist: (a) The contract/certificate shall contain
CONTRACT/CERTIFICATE            DEPARTMENT NO. 1994-             the complete market value adjustment formula. The formula shall be guaranteed and
PROVISIONS                     11/Section 354 of the Insurance   applicable for both upward and downward adjustments. Any rates and factors used in
                               Company Law (40 P. S § 477b)      the market value adjustment formula shall be guaranteed. Nonguaranteed rates and
                                                                 factors may not be included in a contract/certificate.

                                                                 (b) If a certificate contains a table of values: (i) A disclosure shall be made in the
                                                                 proximity of the table that the values are subject to a market value adjustment. (ii) If the
                                                                 form allows for alternative interest rate guarantee periods after the initial interest rate
                                                                 guarantee period, the table shall be based on the default renewal period provided in the
                                                                 form. (c) If the annuitization value is subject to a market value adjustment, the
                              PENNSYLVANIA INSURANCE
                                                                 guarantee period shall not extend more than 6 months beyond the annuitization date in
CONTRACT/CERTIFICATE            DEPARTMENT NO. 1994-
                                                                 effect at the time the guarantee period is elected. (d) If at the end of any guarantee
PROVISIONS                     11/Section 354 of the Insurance
                                                                 period the contract/certificate provides for subsequent guarantee periods of different
                               Company Law (40 P. S § 477b)
                                                                 specified lengths of time, the owner shall have the option of electing a guarantee period
                                                                 for any of the available lengths of time. The contract/certificate shall provide for a
                                                                 default option if the owner does not elect a guarantee period and shall provide that the
                                                                 default option shall not extend the guaranteed period more than 6 months beyond the
                                                                 annuitization date in effect at the time the guarantee period is elected.



                                                       Page 18 of 26
                               PENNSYLVANIA INSURANCE               (e) If the rates or factors used in the market value adjustment formula are no longer
CONTRACT/CERTIFICATE             DEPARTMENT NO. 1994-               available, a substitution shall be submitted to the Department for approval. The request
PROVISIONS                      11/Section 354 of the Insurance     for approval shall include an actuarial memorandum indicating the reasonableness of
                                Company Law (40 P. S § 477b)        the substitution.

                                                                    The following nonforfeiture values - form provision requirements are in addition to the
                                                                    NONFORFEITURE VALUES - FORM PROVISIONS requirements of this checklist:
                                                                    (a) The contract/certificate shall provide sufficient information to determine the
NONFORFEITURE VALUES - FORM    PENNSYLVANIA INSURANCE
                                                                    adjusted cash surrender value, adjusted paid-up annuity benefits and adjusted death
PROVISIONS                      DEPARTMENT NO. 1994-11
                                                                    benefits. (b) The contract/certificate must prominently disclose any rate or factor in the
                                                                    market value adjustment formula to cover items such as transaction costs, timing risk or
                                                                    credit risk. The contract/certificate must explain the reasons for the rate or factor.

                                                                   The following nonforfeiture values - computation of values provision requirements are
                                                                   in addition to the NONFORFEITURE VALUES - COMPUTATION OF VALUES
                                                                   requirements of this checklist: (a) Adjusted cash surrender values and nonforfeiture
                                 Section 410C of the Insurance
                                                                   benefits of a certificate shall comply with the nonforfeiture requirements of the Standard
                                   Company Law (40 P. S. §
                                                                   Nonforfeiture Law for Individual Deferred Annuities (40 P.S. §510b). If the market
NONFORFEITURE VALUES -             510b)/PENNSYLVANIA
                                                                   value adjustment formula includes a rate or factor to cover items, such as transaction
COMPUTATION OF VALUES         INSURANCE DEPARTMENT NO.
                                                                   costs, timing risk or credit risk, this rate or factor is considered an expense charge and
                              1994-11/Section 354 of the Insurance
                                                                   must be included as an expense charge in the nonforfeiture demonstration. (b) If a rate
                                Company Law (40 P. S. § 477b)
                                                                   or factor in the market value adjustment formula is not available for the period
                                                                   remaining in the current guarantee period, the rate or factor shall be determined by
                                                                   interpolating between available rates or factors.

                                                                   (c) A contract/certificate may provide that the interest credited during a guaranteed
                                                                   period may exceed the interest rate guaranteed for that period. The interest credited
                                                                   shall not exceed by more than 1/2 of 1 % the guaranteed interest rate. Guaranteed
                                 Section 410C of the Insurance
                                                                   interest credits in any market value adjustment guarantee period shall be reasonably
                                   Company Law (40 P. S. §
                                                                   related to the average guaranteed interest credits over that period of time. (d) The
NONFORFEITURE VALUES -             510b)/PENNSYLVANIA
                                                                   market value adjustment formula must reflect changes in the market value that occur
COMPUTATION OF VALUES         INSURANCE DEPARTMENT NO.
                                                                   along the interest yield curve. (e) Any loan provision or any partial withdrawal
                              1994-11/Section 354 of the Insurance
                                                                   provision shall be constructed so that general account modified guaranteed annuity
                                Company Law (40 P. S. § 477b)
                                                                   certificate owners who have not exercised such provision are not disadvantaged by the
                                                                   exercise thereof by other general account modified guaranteed annuity certificate
                                                                   owners.




                                                           Page 19 of 26
                                                                 The following disclosure requirements are in addition to the CONTRACT/
                                                                 CERTIFICATE PROVISIONS requirements of this checklist: (a) No later than the
                                                                 time the enrollment form is signed, the applicant shall be provided with a disclosure of
                              PENNSYLVANIA INSURANCE             the certificate features. (b) The disclosure shall explain the principal features of the
                                DEPARTMENT NO. 1994-             certificate, including a description of the manner in which the cash surrender values will
DISCLOSURE
                               11/Section 354 of the Insurance   be affected by the market value adjustment and the factors which affect such variation.
                              Company Law (40 P. S. § 477b)      If applicable, a description of the manner in which the death benefit will be affected by
                                                                 the market value adjustment. A disclosure shall be made that the cash surrender values
                                                                 and paid-up annuity benefits after the market value adjustment are subject to the
                                                                 minimum values defined in the contract/certificate.
                                                                 The following report to owner requirements are in lieu of the REPORT TO OWNER
                              PENNSYLVANIA INSURANCE             requirements of this checklist. (a) A contract/certificate shall provide for the delivery,
                                DEPARTMENT NO. 1994-             at least annually and without charge, of a report to the certificate owner which serves to
REPORT TO CERTIFICATE OWNER
                               11/Section 354 of the Insurance   keep the certificate owner advised as to the status of the certificate. (b) The end of the
                              Company Law (40 P. S. § 477b)      current report period may not be more than 3 months prior to the date of the mailing of
                                                                 the report.

                                                                 (c) The repost shall contain at least the following information: (i) The beginning and
                                                                 ending date of the current report period. (ii) The account value, if any, at the beginning
                                                                 of the current report period and at the end of the current report period. (iii) The cash
                              PENNSYLVANIA INSURANCE             surrender value, if any, at the end of the current report period. (iv) A statement that the
                                DEPARTMENT NO. 1994-             cash surrender value includes a reduction for the surrender charge and for a market
REPORT TO CERTIFICATE OWNER
                               11/Section 354 of the Insurance   value adjustment. (v) The amounts, if any, that have been credited or debited to the
                              Company Law (40 P. S. § 477b)      form during the current report period. The credited and debited amounts shall be
                                                                 identified by type; for example, premium payments, interest credits, bonus credits,
                                                                 expense charges, withdrawal amounts and withdrawal charges. (vi) The amount of
                                                                 outstanding loans, if any, as of the end of the current report period.




                                                       Page 20 of 26
SEPARATE ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY (A deferred annuity under which the values are subject to a market value adjustment unless held
for guaranteed periods specified in the contract/certificate.)
                                                                              The submission package shall include in addition to the SUBMISSION PACKAGE
                                                                              REQUIREMENTS of this checklist, the following: (a) State that the
                                                                              contract/certificate contains a market value adjustment provision. (b) If a guaranteed
                                                                              minimum interest rate(s) is included in the contract/certificate as a variable, a
                                                                              certification that any change in the guaranteed minimum interest rate(s) used in the
                                               Section 354 of the Insurance   calculation of the adjusted cash value will be submitted for approval prior to use. Any
        SUBMISSION PACKAGE
                                              Company Law (40 P. S. § 477b)   change in the rate(s) may be contained in an endorsement, replacement page or
                                                                              complete new contract/certificate. The submission for approval shall be accompanied
                                                                              by a demonstration that the contract/certificate continues to comply with the
                                                                              SEPARATE ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY -
                                                                              NONFORFEITURE VALUES-COMPUTATION OF VALUES section of this
                                                                              checklist.
                                                                              (c) If guaranteed maximum expense charge(s), surrender charge(s), or partial
                                                                              withdrawal charge(s) are included in the contract/certificate as a variable, a certification
                                                                              that any change in the guaranteed maximum variable charge(s) used in the calculation of
                                                                              the adjusted cash value will be submitted for approval prior to use. Any change in the
                                               Section 354 of the Insurance   charge(s) may be contained in an endorsement, replacement page or complete new
        SUBMISSION PACKAGE
                                              Company Law (40 P. S. § 477b)   contract/certificate. The submission for approval shall be accompanied by a
                                                                              demonstration that the contract/ certificate continues to comply with the SEPARATE
                                                                              ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY -
                                                                              NONFORFEITURE VALUES-COMPUTATION OF VALUES section of this
                                                                              checklist.

                                                                              (d) If the market value adjustment formula or any rates or factors used in the market
                                                                              value adjustment formula are included in the contract/certificate as a variable, a
                                                                              certification that any change in the formula or any rate or factor used in the formula will
                                                                              be submitted to the Department for approval prior to use. If the market value
                                                                              adjustment formula is revised, the request for approval shall include an actuarial
                                                                              memorandum submitted in accordance with the SEPARATE ACCOUNT MODIFIED
                                               Section 354 of the Insurance   GUARANTEED DEFERRED ANNUITY - ACTUARIAL MEMORANDUM
        SUBMISSION PACKAGE
                                              Company Law (40 P. S. § 477b)   requirements of this checklist. If any rates or factors used in the formula are revised, the
                                                                              request for approval shall include an actuarial memorandum indicating the
                                                                              reasonableness of the revised rate or factor. Any change in the formula or any rates or
                                                                              factors used in the formula may be contained in an endorsement, replacement page or
                                                                              complete new contract/certificate. (e) A certification that the insurer has obtained the
                                                                              written approval of the Commissioner for the issuance of separate account annuity
                                                                              (includes variable) contracts in Pennsylvania.


                                                                     Page 21 of 26
                                                        The following actuarial memorandum requirements are in lieu of the ACTUARIAL
                                                        MEMORANDUM requirements of this checklist. An actuarial memorandum which
                                                        provides: (a) A description of the contract/certificate and provisions which affect
                                                        nonforfeiture values. (b) An identification of market value adjustment guarantee periods
                       PENNSYLVANIA INSURANCE           of time available at issue of the contract/certificate. (c) All guaranteed maximum
                        DEPARTMENT NO. 1994-12/         surrender and expense charges. (d) A statement that the market value adjustment
ACTUARIAL MEMORANDUM
                         Section 354 of the Insurance   formula provides reasonable equity to both the owner and the insurer and the basis for
                        Company Law (40 P. S. § 477b)   this statement. (e) A sample calculation of the account value, surrender charge, both an
                                                        upward and downward market value adjustment and adjusted cash surrender value for
                                                        each schedule of surrender charges. The calculations shall properly reflect any
                                                        withdrawal amounts made during the surrender charge period that are not subject to a
                                                        surrender charge.

                                                        f) If the market value adjustment provision refers to an index outside the control of the
                                                        insurer, an explanation of the reasonableness of the index. Any request for Department
                                                        acceptance of the substitution of an index outside the control of the insurer shall include
                                                        an actuarial memorandum indicating the reasonableness of the substitute index. (g) If
                       PENNSYLVANIA INSURANCE
                                                        the market value adjustment formula contains a factor that represents a charge to cover
                        DEPARTMENT NO. 1994-12/
ACTUARIAL MEMORANDUM                                    items such as transaction costs, timing risk and/or credit risk, an explanation how this
                         Section 354 of the Insurance
                                                        charge relates to each of these items. (h) A nonforfeiture demonstration that the cash
                        Company Law (40 P. S. § 477b)
                                                        surrender values before the market value adjustment comply with the requirements of
                                                        the SEPARATE ACCOUNT MODIFIED GUARANTEED DEFERRED ANNUITY-
                                                        NONFORFEITURE VALUES-COMPUTATION OF VALUES section of this
                                                        checklist. The demonstration shall be provided at critical premium amounts and ages.

                                                        i) If the contract/certificate provides for partial withdrawals, two numeric examples
                                                        illustrating the application of the market value adjustment to partial withdrawals,
                                                        including how any minimum on the amount of the market value adjustment will be
                       PENNSYLVANIA INSURANCE
                                                        administered on partial withdrawals. One example shall illustrate a partial withdrawal
                        DEPARTMENT NO. 1994-12/
ACTUARIAL MEMORANDUM                                    occurring with a significant downward market value adjustment, followed shortly
                         Section 354 of the Insurance
                                                        thereafter by a full surrender with an upward market value adjustment. The other
                        Company Law (40 P. S. § 477b)
                                                        example shall illustrate a partial withdrawal occurring with a significant downward
                                                        market value adjustment, followed shortly thereafter by a full surrender with a
                                                        significant downward market value adjustment.




                                              Page 22 of 26
                                                                 (j) A table of cash surrender values for the first 10 years of the certificate illustrating an
                                                                 initial guarantee period and at least one renewal guarantee period. The table shall be
                                                                 based on the guaranteed minimum interest rate or rates and maximum expense and
                                                                 surrender charges. If the contract/certificate allows for alternative interest rate
                              PENNSYLVANIA INSURANCE
                                                                 guarantee periods after the initial interest rate guarantee period, the table shall be based
                               DEPARTMENT NO. 1994-12/
ACTUARIAL MEMORANDUM                                             on the default renewal period provided in the form. The table shall be based on level
                                Section 354 of the Insurance
                                                                 premiums payable once each year. (k) The range of issue ages. (l) The maximum
                               Company Law (40 P. S. § 477b)
                                                                 maturity date, if the contract/certificate provides for optional maturity dates. (m) The
                                                                 fixed maturity date, if applicable. (n) For insurers domiciled in Pennsylvania, a
                                                                 description, with formulas and an example, of the methodology of the calculation of
                                                                 reserves. (o) Signature of the actuary who prepared the actuarial memorandum.

                                                                 The following general form requirements are in addition to the GENERAL FORM
                              PENNSYLVANIA INSURANCE             REQUIREMENT - COVER PAGE requirements of this checklist: The cover page of a
                               DEPARTMENT NO. 1994-12/           modified guaranteed annuity contract/certificate shall contain a statement that cash
                                                                 surrender values may increase or decrease in accordance with a market value
GENERAL FORM REQUIREMENTS -                                      adjustment prior to a date or dates specified in the contract/certificate. A statement
COVER PAGE                                                       shall be made that any increase or decrease in the cash surrender values is subject to the
                                                                 minimum values defined in the contract/certificate. A statement shall also be included
                                   § 89.11(d) of Title 31        of the effect, if any, that a market value adjustment has on the death benefit. The
                                                                 statement(s) shall appear in a prominent location in prominent type on the cover page or
                                                                 caption.
                                                                 The following general form requirement is in addition to the GENERAL FORM
                                                                 REQUIREMENTS - VARIABILITY requirements of this checklist: Any information
                                                                 appearing in the contract/certificate which is variable shall be bracketed or otherwise
GENERAL FORM REQUIREMENTS -    Section 354 of the Insurance
                                                                 marked to denote variability. In addition to the variable items referenced in GENERAL
VARIABILITY                   Company Law (40 P. S. § 477b)
                                                                 FORM REQUIREMENTS - VARIABILITY, variability is limited to the market value
                                                                 adjustment formula and any rates or factors used in the market value adjustment
                                                                 formula.
                                                                 The following contract/certificate provisions are in addition to the CONTRACT/
                              PENNSYLVANIA INSURANCE             CERTIFICATE requirements of this checklist: (a) The contract/certificate shall contain
CONTRACT/CERTIFICATE             DEPARTMENT NO 1994-             the complete market value adjustment formula. The formula shall be guaranteed and
PROVISIONS                     12/Section 354 of the Insurance   applicable for both upward and downward adjustments. Any rates and factors used in
                               Company Law (40 P. S. § 477b)     the market value adjustment formula shall be guaranteed. Nonguaranteed rates and
                                                                 factors may not be included in a contract/certificate.




                                                       Page 23 of 26
                                                                 (b) If a certificate contains a table of values: (i) A disclosure shall be made in the
                                                                 proximity of the table that the values are subject to a market value adjustment. (ii) If the
                                                                 form allows for alternative interest rate guarantee periods after the initial interest rate
                                                                 guarantee period, the table shall be based on the default renewal period provided in the
                                                                 form. (c) If the annuitization value is subject to a market value adjustment, the
                              PENNSYLVANIA INSURANCE
                                                                 guarantee period shall not extend more than 6 months beyond the annuitization date in
CONTRACT/CERTIFICATE            DEPARTMENT NO. 1994-
                                                                 effect at the time the guarantee period is elected. (d) If at the end of any guarantee
PROVISIONS                     12/Section 354 of the Insurance
                                                                 period the contract/certificate provides for subsequent guarantee periods of different
                               Company Law (40 P. S § 477b)
                                                                 specified lengths of time, the owner shall have the option of electing a guarantee period
                                                                 for any of the available lengths of time. The contract/ certificate shall provide for a
                                                                 default option if the owner does not elect a guarantee period and shall provide that the
                                                                 default option shall not extend the guaranteed period more than 6 months beyond the
                                                                 annuitization date in effect at the time the guarantee period is elected.
                              PENNSYLVANIA INSURANCE             (e) If the rates or factors used in the market value adjustment formula are no longer
CONTRACT/CERTIFICATE            DEPARTMENT NO. 1994-             available, a substitution shall be submitted to the Department for approval. The
PROVISIONS                     12/Section 354 of the Insurance   request for approval shall include an actuarial memorandum indicating the
                               Company Law (40 P. S § 477b)      reasonableness of the substitution.

                                                                 The following nonforfeiture values - form provision requirements are in addition to the
                                                                 NONFORFEITURE VALUES - FORM PROVISIONS requirements of this checklist:
                                                                 (a) The contract/certificate shall provide sufficient information to determine the
NONFORFEITURE VALUES - FORM   PENNSYLVANIA INSURANCE
                                                                 adjusted cash surrender value, adjusted paid-up annuity benefits and adjusted death
PROVISIONS                     DEPARTMENT NO. 1994-12
                                                                 benefits. (b) The contract/certificate must prominently disclose any rate or factor in the
                                                                 market value adjustment formula to cover items such as transaction costs, timing risk or
                                                                 credit risk. The contract/certificate must explain the reasons for the rate or factor.


                                                                 The following nonforfeiture values - computation of values provision requirements are
                                                                 in addition to the NONFORFEITURE VALUES - COMPUTATION OF VALUES
                                                                 requirements of this checklist. (a) Cash surrender values and nonforfeiture benefits of a
                              PENNSYLVANIA INSURANCE             certificate before the market value adjustment shall comply with the nonforfeiture
NONFORFEITURE VALUES -          DEPARTMENT NO. 1994-             requirements of (b)-(e), as follow. If the market value adjustment formula includes a
COMPUTATION OF VALUES          12/Section 354 of the Insurance   rate or factor to cover items, such as transaction costs, timing risk or credit risk, this rate
                               Company Law (40 P. S. § 477b)     or factor is considered an expense charge and must be included as an expense charge in
                                                                 the nonforfeiture demonstration. (b) If a rate or factor in the market value adjustment
                                                                 formula is not available for the period remaining in the current guarantee period, the
                                                                 rate or factor shall be determined by interpolating between available rates or factors.




                                                       Page 24 of 26
                                                                 (c) A contract/certificate may provide that the interest credited during a guaranteed
                                                                 period may exceed the interest rate guaranteed for that period. The interest credited
                                                                 shall not exceed by more than 1/2 of 1 % the guaranteed interest rate. Guaranteed
                                                                 interest credits in any market value adjustment guarantee period shall be reasonably
                              PENNSYLVANIA INSURANCE
                                                                 related to the average guaranteed interest credits over that period of time. (d) The
NONFORFEITURE VALUES -          DEPARTMENT NO. 1994-
                                                                 market value adjustment formula must reflect changes in the market value that occur
COMPUTATION OF VALUES          12/Section 354 of the Insurance
                                                                 along the interest yield curve. (e) Any loan provision or any partial withdrawal
                               Company Law (40 P. S. § 477b)
                                                                 provision shall be constructed so that separate account modified guaranteed annuity
                                                                 certificate owners who have not exercised such provision are not disadvantaged by the
                                                                 exercise thereof by other separate account modified guaranteed annuity certificate
                                                                 owners.

                                                                 The following disclosure requirements are in addition to the
                                                                 CONTRACT/CERTIFICATE PROVISIONS requirements of this checklist: (a) No
                              PENNSYLVANIA INSURANCE             later than the time the enrollment form is signed, the applicant shall be provided with a
                                DEPARTMENT NO. 1994-             disclosure of the certificate features. (b) The disclosure shall explain the principal
DISCLOSURE
                               12/Section 354 of the Insurance   features of the certificate, including a description of the manner in which the cash
                               Company Law (40 P. S. § 477b)     surrender values will be affected by the market value adjustment and the factors which
                                                                 affect such variation. If applicable, a description of the manner in which the death
                                                                 benefit will be affected by the market value adjustment.

                                                                 The following report to owner requirements are in lieu of the REPORT TO OWNER
                              PENNSYLVANIA INSURANCE             requirements of this checklist. (a) A contract/certificate shall provide for the delivery,
                                DEPARTMENT NO. 1994-             at least annually and without charge, of a report to the certificate owner which serves to
REPORT TO CERTIFICATE OWNER
                               12/Section 354 of the Insurance   keep the certificate owner advised as to the status of the certificate. (b) The end of the
                               Company Law (40 P. S. § 477b)     current report period may not be more than 3 months prior to the date of the mailing of
                                                                 the report.

                                                                 (c) The repost shall contain at least the following information: (i) The beginning and
                                                                 ending date of the current report period. (ii) The account value, if any, at the beginning
                                                                 of the current report period and at the end of the current report period. (iii) The cash
                              PENNSYLVANIA INSURANCE             surrender value, if any, at the end of the current report period. (iv) A statement that the
                                DEPARTMENT NO. 1994-             cash surrender value includes a reduction for the surrender charge and for a market
REPORT TO CERTIFICATE OWNER
                               12/Section 354 of the Insurance   value adjustment. (v) The amounts, if any, that have been credited or debited to the
                               Company Law (40 P. S. § 477b)     form during the current report period. The credited and debited amounts shall be
                                                                 identified by type; for example, premium payments, interest credits, bonus credits,
                                                                 expense charges, withdrawal amounts and withdrawal charges. (vi) The amount of
                                                                 outstanding loans, if any, as of the end of the current report period.




                                                       Page 25 of 26
SPECIALIZED MARKETING – ADDITIONAL REQUIREMENTS

FIELD ISSUE (The marketing practice where the producer issues the contract/certificate to the applicant immediately at the point of sale and delivers the
contract/certificate at the point of sale; the insurer does not issue the contract/certificate.)

                                                                                     At the time of contract/certificate issue (simultaneous with application/enrollment
                                                    Section 410E of the Insurance
                                                                                     form), the contract/certificate shall contain a specifications page, or the information
         CONTRACT/CERTIFICATE                      Company Law (40 P. S. § 510d)/
                                                                                     normally disclosed on the specifications page shall be clearly disclosed on the
         PROVISIONS                                  Section 354 of the Insurance
                                                                                     application/enrollment form apart from any questions and the representation/agreement
                                                   Company Law (40 P. S. § 477b)
                                                                                     section of the application/enrollment form.

                                                     Section 410E of the Insurance   If a specifications page is provided after the contract/certificate is issued, the right to
         CONTRACT/CERTIFICATE                       Company Law (40 P. S. § 510d)    examine provision included in the issued contract/certificate shall provide that another
         PROVISIONS                                   Section 354 of the Insurance   right to examine period will be provided beginning when the specifications page is
                                                    Company Law (40 P. S. § 477b)    received
                                                     Section 354 of the Insurance
         CONTRACT /CERTIFICATE COVER               Company Law (40 P. S. § 477b)/    The application/enrollment form shall not be substituted for the contract/certificate
         PAGE                                       Section 410E of the Insurance    cover page or obscure the contract/certificate cover page.
                                                   Company Law (40 P. S. § 510d)




                                                                            Page 26 of 26

				
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